Important Regulatory Information
Sloane Robinson LLP (Sloane Robinson) is established as a Limited Liability Partnership in England and Wales (No. OC309313) with its registered office at 36 Queen Street, London. EC4R 1BN. Sloane Robinson is authorised and regulated by the Financial Conduct Authority in the United Kingdom (Firm Reference Number 409159).
This website does not constitute an offer or solicitation to any person in any jurisdiction to purchase or sell any investment. No information on this website should be construed as providing financial, investment or other professional advice. This website and the information contained herein is made available for information purposes only. The information on this website is directed only at persons or entities where such access and use of information is not contrary to local or regulation. Investment with Sloane Robinson is open to institutional and other sophisticated investors and is not available to the general retail public.
Important Jurisdictional Regulatory Information
Access to the information contained on this website in respect of the funds managed and services offered by Sloane Robinson is restricted in various jurisdictions. All persons accessing this website do so at their own initiative and are required to inform themselves of, and comply with, all such restrictions. Funds and services referred to on this website are not available to, and offering materials will not be distributed to, any person resident in any jurisdiction where such distribution would contrary to law or regulation. The information contained on this website does not constitute an offer to buy or sell any investment. No information on this website should be construed as providing financial, investment or other professional advice. For jurisdictional regulatory information please access the Important Jurisdictional Regulatory Notice here.
For details on why and how we use your data and the rights that you have in relation to this, please see the Privacy Notices below:
Where we use your organisation for certain brokerage services, we and you will have in place appropriate execution, research or corporate access terms of business in respect of those services that you provide. These terms of business will in each case refer to supplemental terms and conditions in respect of the controlling and processing of personal data. Please see such supplemental terms and conditions below:
Sloane Robinson has documented the disclosures required by the FCA under BIPRU 11.3. These are available on the firm's website (under the news section) for registered users or from Sloane Robinson's Compliance Officer at the registered office.
Under FCA Rules, Sloane Robinson is required to take all sufficient steps to obtain the best possible result on a consistent basis when executing client orders or placing orders with other entities for execution, taking into account a range of execution factors, including price, costs, speed, size, nature of the order, likelihood of execution and settlement, and any other consideration relevant to the execution of the order. Further details of Sloane Robinson's Order Execution Policy are available on request.
As part of the best execution requirements under the Markets in Financial Instruments Directive ("MiFID"), investment firms are required to provide various disclosures in respect of the venues used for the execution of transactions they have undertaken on behalf of clients to whom they provide MiFID services. The Firm makes the following disclosures for 2018:
Please note that the disclosures only provide information in respect of Sloane Robinson's MiFID activities; they do not include any transaction details in respect of services provided by Sloane Robinson to its non-MiFID clients and the disclosures should therefore not be considered as being representative of Sloane Robinson's wider trading activities on behalf of clients during the period.
Stewardship and Shareholder Engagement
Sloane Robinson is subject to and required to comply with the requirements of Article 3g(a) of Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017 amending Directive (EU) 2017/36/EC as regards the encouragement of long-term shareholder engagement (“SRD II”), by making certain information available on this website in relation to its compliance with various requirements under SRD II in respect of its engagement with the companies in which Sloane Robinson invests on behalf of its clients, or by providing a clear and reasoned explanation as to any decision not to comply.
The following Shareholder Engagement Policy contains Sloane Robinson’s disclosures in respect of SRD II: Shareholder Engagement Policy.
Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Sloane Robinson is also required to include on this website a disclosure about the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non-compliance. Although certain aspects of Sloane Robinson’s Shareholder Engagement Policy relating to matters such as proxy voting and managing of conflicts of interest may be relevant to the Code, Sloane Robinson does not consider it appropriate to commit to compliance with the Code (or at this time, any other voluntary code of practice specific to any individual jurisdiction) on the basis that it takes a consistent global approach to engagement with issuers and their management in all of the jurisdictions in which it invests.
Financial Crime Statement
We seek to comply with high standards of anti-money laundering, counter terrorist financing practice, anti bribery and economic sanctions in all our business dealings. We take our duty of compliance extremely seriously and have established strong policies and procedures to manage these issues, including awareness training, record keeping and compliance monitoring. We value our reputation for ethical behaviour and recognise that over and above the commission of any crime any involvement in bribery or corruption would of itself be unacceptable. We absolutely forbid corruption and the paying or receipt of bribes.
Sloane Robinson Policies
Sloane Robinson maintains various policies and procedures to ensure the proper provision of services to clients, including in relation to the management of conflicts of interest, personal account dealing, anti-bribery and money laundering, order allocation and resolution of dealing errors. Further details of these policies are available on request. Please note that Sloane Robinson's policy on the resolution of dealing errors has been updated. The key points of the policy are: (1) losses associated with a dealing error for which Sloane Robinson is contractually responsible will be borne by the firm and (2) gains resulting from a dealing error will be credited to and retained by the client.